ML20099L222
| ML20099L222 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 09/06/1995 |
| From: | GEORGIA POWER CO. |
| To: | |
| Shared Package | |
| ML20099L220 | List: |
| References | |
| OLA-3-A-170, NUDOCS 9512200173 | |
| Download: ML20099L222 (16) | |
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L GPC EXHIBIT II 870 f**'
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00CKETED USHRC
/)/ A') rt wt l *W 00120 P 3 :49 Numerous sensor caliberations (including J Cke pateeRETARY ~
temeperatures), special pneumatic leak toa MdimbltM[e engine starts and runs were performed unde toumHCli l
conditions. In addition, the control systems foF both I engines were subjected to a comprehensive test program.
Af ter completion of the control logicIncluding test sequence, the under an under voltage test was performed.
voltage test each engine has been successfully started
- eleven times with no start failures. _
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1 NUCLEAR REGULATORY COMMISSION Docket No. 50-424/425-OLA-3 EXHIBITNO._ 6 8C 11-170 in the matter of Georcia Power Co. et at . Voatie Units 1 & 2 O statt G Applicant O intervonor O Other
@ldentified @ Received O Re}ected Reporter 6D one 04 - c 6 - 49 witness Wen e" e 9512200173 950906 PDR ADOCK 05000424 0 PDR
- 4 A
August 14, 1995 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of :
- Docket Nos. 50-424-OLA-3 GEORGIA POWER COMPANY, gt. al. : 50-425-OLA-3 (Vogtle Electric Generating Plant, : Re: License Amendment Units 1 and 2) : (Transfer to
- Southern Nuclear
- ASLBP No. 93-671-OLA-3 i PREFILED REBUTTAL TESTIMONY
. OF THOMAS E. WEBB ON DIESEL GENERATOR REPORTING ISSUES i
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PREFILED REBUTTAL TESTIMONY OF THOMAS E. WEBB l
. 1 Q: PLEASE STATE YOUR FULL NAME.
2 A: My name is Thomas Edmund Webb. l l
3 Q: WHAT ARE YOUR PROFESSIONAL QUALIFICATIONS?
4 A: A summary of my professional qualifications is attached
- 5 hereto as Exhibit A.
6 Q: WHAT POSITION DID YOU HOLD IN 1990?
7 A: In-1990 I held the same position which I hold now, which i
l 8 is Senior Engineer in the Nuclear Safety and Compliance
! 9 (NSAC) group in the Technical Support Department of the 10 Vogtle Electric Generating Plant.
11 Q: WHAT WERE YOUR RESPONSIBILITIES IN THAT POSITION AND TO 12 WHOM DID YOU REPORT?
t 13 A: My responsibilities encompassed regulatory / licensing f 14 assistance to the Plant, including the preparation of
- 15 Licensee Event Reports ("LERs") for submittal _to the NRC a
16 pursuant to 10 CFR 5 50.73. My supervisor at the time 17 was Mr. Rick Odom who, in turn, reported to John 18 Aufdenkampe.
4 19 Q: WHAT WAS YOUR INVOLVEMENT IN THE PREPARATION OF THE APRIL 4
20 19, 1990 LER ASSOCIATED WITH THE MARCH 20, 1990 SITE AREA 21- EMERGENCY EXPERIENCED?
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i 1 A: I prepared various drafts for review and approval by my 2 supervisor and by the Vogtle Plant Review Board ("PRB").
3 4 Q: MR. MOSBAUGH STATES THAT YOU RECOUNTED TO HIH "THE 5 HISTORY OF HOW GPC PERSONNEL KNEW THE LER WAS 6 QUESTIONABLE BEFORE IT WAS SIGNED OUT." (ALLEN MOSBAUGH 7 RETYPED PREFILED TESTIMONY AT 37). PLEASE DESCRIBE THE 8 HISTORY OF EFFORTS IN PREPARING THE LER.
9 A: Shortly after the March 20, 1990 event, Mr. Odom directed 10 me to prepare a draf t LER for the event. I completed the 11 first draft and submitted it for review to my " acting" 12 supervisor, Mr. Mehdi Sheibani, and Mr. Aufdenkampe. On 13 or about April 9, 1990, Mr. Aufdenkampe instructed me to l l
14 include a Unit 1 Diesel Generator-related statement about 15 starts which Georgia Power had previously provided the 16 NRC in the April 9, 1990 confirmation of action response 17 letter (McCoy Exh. K; GPC Exh. II-13). On April 10, I
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18 completed another draft of the LER, received additional l
19 comments from him, and on April 11, 1990 completed a 20 third draft of the LER. This draft was telecopied to Mr.
21 Norman " Jack" Stringfellow in the Vogtle Project office 1
22 in Birmingham and submitted to the PRB. j l
23 Q: WAS THIS DRAFT LER APPROVED?
24 A: No. The PRB members reviewed this draft during the April 25 12, 1990 PRB meeting and returned it to me with
,_ f t 1 1 instructions to rewrite it so that the LER would be no 2 longer than eight pages; the draf t which I had submitted 3 was substantially longer than that.
l l 4 Q: DID YOU SUBMIT ANOTHER DRAFT LER TO THE PRB?
5 A: Yes. On April 13, 1990, I completed a fourth draft of 6 the LER and submitted it to Mr. Aufdenkampe. Mr.
7 Aufdenkampe had additional comments, including a comment l 8 to the ef fect that the "18 and 19 starts" language in the 1
9 draft LER might not be correct. At'my suggestion, the 10 draft was revised to read "Since 3-20-90, DG1A and DG1B 11 have been started several times and no failures or i
12 problems have occurred during any of these starts." This 13 was incorporated in the fifth draft which I sent to Mr.
14 Stringfellow. On April 16 I received comments on this l l !
15 fifth draft from the corporate office which did not 16 concern the diesel generator starts statement. On April 17 17, 1990, I completed the sixth draft of the LER, 18 received additional comments from Mr. McCoy (via Mr.
19 Aufdenkampe) and completed the seventh draft of the LER.
20 This, also, I forwarded to Mr. Stringfellow.
21 On April 18, 1990, the PRB reviewed the seventh 22 draft of the LER and approved it by unanimous vote 23 subject to a number of comments. The minutes of this PRB l
24 meeting (No. 90-59) are attached to Mr. Aufdenkampe's 25 testimony as Exhibit B (GPC Exh. II-28).
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.2 CONCERN ABOUT THE DIESEL STARTS NUMBERS (ALLEN MOSBAUGH 3 RETYPED PREFILED TESTIMONY AT 53). DID ANY OF THE 4 COMMENTS FROM THE EARLIER APRIL 18 PRB PERTAIN TO DIESEL 1 1
5 GENERATOR STARTS STATEMENT?
6 A: Yes. One of the various PRB comments on April 18 was 7 that the word "several" in the seventh draft should be 8 replaced with the actual number of starts. After the PRB 9 meeting, I initiated a review of diesel generator start l 10 data and, upon completion that same day, concluded that 11 21 and 23 starts should be used in lieu of 18 and 19, 12 respectively. I reached this conclusion by adding 13 additional starts without problems or failures occurring l
l 14 after April 9, 1990 to the numbers of starts identified l
15 in the April 9 letter. I identified these additional 16 starts by reviewing the control room logs for the period
! 17 April 10 through the morning of April 18, inclusive, and )
l 18 by speaking to Mr. Ken Stokes. Mr. Stokes informed me of 19 one additional start on the 1B diesel generator on April 20 18th. I incorporated the PRB comments into the eighth 21 draft of the LER, sent a copy of it to Mr. Stringfellow, 22 and submitted it to Mr. George Bockhold, the Plant
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i 1 General Manager, who approved it without comment. The l 2 revised statement read:
j 3 Numerous sensor calibrations (including jacket water 4 temperatures), special pneumatic leak testing, and 5 multiple engine starts and runs were performed under 6 various conditions. Since 3-20-90, DG 1A and DG 1B have 7 baen started more than twenty times each and no failures )
8 or problems have occurred during any of these starts. In {
9 addition, an undervoltage start test without air roll was I
'10 conducted on 4-6-90 and DG1A started and loaded properly 1
11 Q: WAS THIS APRIL 18 DRAFT LER SENT TO THE NRC? l 4
12 A: No. Although it had been approved by the site, further
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13 comments were received from the corporate office.
l l 14 Q: WHAT WERE THE CORPORATE OFFICE COMMENTS RELATED TO DIESEL
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15 GENERATORS?
l 16 A: On April 19, Mr. Aufdenkampe received several comments.
l 17 One comment from the corporate office was to verify the 18 "more than twenty times each" language in the eighth l 19 draft. I was directed by Mr. Odom to verify the "more 20 than twenty times each" language. I, and, I believe, Mr.
21 Herb Beacher (another employee in the NSAC group) then 22 reviewed the control room logs for the period _of March 23 20, 1990 through April 18, 1990, inclusive. The control 24 room logs consisted of the Unit Control Log and the Shift 25 Supervisor Log. I knew the Engineering Support 26 Departments' Diesel Start Log was not up-to-date because 27 there was a lag in the log updating. I also did not have 28 available the individual diesel generator start sheets 29 (i.e., the "Conpletion Sheets" from procedure 13145),
I which are supposed to be filled out by operators for each 2 start.
3 Q: DID YOU DEVELOP ANY DOCUMENTATION OF THE STARTS?
4 A: Yes, I developed a list of all the documented starts.
i i 5 The list identified some starts which had experienced l 6 problems or failures. My efforts began in the early 7 af ternoon of April 19th (around lunch time) and continued 8 until after normal quitting time. During the process, I j i I 9 was periodically contacted by Messrs. Odom and j 10 Aufdenkampe, and they requested my completed list. l 11 Basically, the list included the date and time of a start 12 and would note any problems annotated in the control room i 13 logs.
14 Q: WHAT DID YOU DO WITH YOUR LIST?
- 15 A
- I delivered my list to Mr. Odom who, I believe, then i
16 provided the list to Mr. Aufdenkampe or Mr. Mosbaugh late 17 in the afternoon of April 19, 1990.
18 Q: IS THE LIST YOU PREPARED THE SAME AS GPC EXHIBIT 71?
19 A: Yes, GPC Exhibit II-71 is a photocopy of my original 20 list. However, some of the information shown on GPC 21 Exhibit II-71 is not my handwriting and was not on the
'22 list delivered to Mr. Odom, including the information in i
23 red ink and in black ink on the original of the document )
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1 identified as GPC Exhibit II-71. The line near the top 2 of the page is crossed out in pencil, probably by me.
3 Q: DID YOU PERSONALLY VERIFY THE FINAL LER STATEMENT i
l 4 CONCERNING DIESEL GENERATOR STARTS WHICH REFERRED TO THE l 5 " COMPREHENSIVE TEST PROGRAM" OF THE CONTROL SYSTEMS?
6 A: No. While I thought that I was tasked by Mr. Odom to I 7 verify the diesel start statement in the LER which had 8 been approved by the PRB, no one ever got back to me to 9 further review the LER wording after I compiled my list.
1 10 Q: MR. MOSBAUGH HAS TESTIFIED THAT HE FIRST SAW THE TEXT OF l
11 THE FINAL LER 90-006 A DAY OR SO AFTER IT WAS SENT TO THE 12 NRC. (ALLEN MOSBAUGH RETYPED PREFILED TESTIMONY AT 53).
l 13 WHEN DID YOU FIRST OBTAIN AND REVIEW A COPY OF THE FINAL l
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14 LER WHICH HAD BEEN SIGNED BY MR. HAIRSTON AND SENT TO THE 15 NRC?
16 A: On April 20, 1990. As I recall, Mr. Mosbaugh was with me l
! 17 when I first reviewed the telecopy of the final LER from 18 the corporate office on April 20th. I was surprised to 19 see words similar to " subsequent to the test program" 20 inserted into the LER. I wasn't sure what it meant.
21 This phrase, I thought, could cause the LER statement to 22 be incorrect, since I recalled identifying on April 19th 23- only about 10 or 11 starts following the return to 24 operability of the diesel engines. I recall Mr. Mosbaugh
1 looking over my shoulder as I read the final LER. I said 2 something to the effect of "Oh, [ expletive). That's 3 wrong. What does ' subsequent to the test program' mean?"
4 In response to my question Mr. Mosbaugh said, in effect, 5 that he knew the LER statement appeared to be wrong, but 6 he also said he did not know what the statement 7 " subsequent to the test program" meant. ,
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- 8 Q: DID YOU REVISE THE LER? 7 l JI l 9 After I had informed Mr. Mosbaugh that the LER' appeared A:
10 to be incorrect, I also informed Mr. Odom, I believe. On !
l 11 or about April 30, 1990, Mr. Odom informed me that the
! 12 LER would be revised to reflect a current diesel 13 generator statement. At that time, I first received two )
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14 hand-written sets of diesel generator starts data from 15 Mr. Mosbaugh. One set was entitled "DG1A Start History 16 for March and April," Intervenor Exhibit II-150, which l 17 had been prepared by Mr. Stokes. The second set of data i
l 18 was entitled "DG1B" (GPC Exhibit II-70) and had been
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19 prepared by Mr. Mosbaugh. I prepared a draft revision.
20 Q: DID YOU DEVELOP AND SUBMIT TO THE PRB A REVISION TO LER 21 90-006?
22 A: Yes. Based upon comments and review by my supervisor and 23 manager of two drafts, a third revision was prepared and 24 this one was submitted to the PRB on May 8, 1990. It
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2 After the 3-20-90 event, the control systems of 3 both engines were subjected to a comprehensive test !
l 4 program which culminated in control logic tests on l 5 3-30-90 for DG1A and 3-27-90 for DG1B. Subsequent l 6 to this test program, DG1A and DG1B have been l 7 started 11 times each (through 4-19-90) and no i 8 failures or problems have occurred during any of l 9 these starts. .These included an undervoltage start 10 test without air roll which was conducted on 4-6-90 l 11 and DG1A started and loaded properly. )
12 Q: WHEN DID THE PRB APPROVE THIS DRAFT REVISION TO THE LER?
l 13 A: On May 8,1990, the PRB approved, with comment, the draf t 14 revision. Mr. George Frederick asked for clarification 15 concerning the meaning of the " comprehensive test l 16 program". Mr. Allen Mosbaugh provided a rewrite of the 17 revision to address Mr. Frederick's comment. A copy of
! 18 his wording, with " ALM rewrite" annotated at the top, is l
19 attached hereto as Exhibit B. This fourth draft revision 20 was given to George Bockhold. Mr. Bockhold returned this 21 draf t with a comment. The comment stated: " Include both 22 the successful starts as of 4/19 and 5/14." This was 23 written on a " Post-It" sticker and sent to me through Tom 24 Greene on or about May 14, 1990. The fifth draft 25 revision only partly incorporated his comment and stated, 26 in part, that "DG1A had been successfully started 15 27 times and DG1B had been successfully started 14 times as l l
28 of 5-14-90, with no start failures." I sent this draft j 29 revision to Jack Stringfellow in the corporate office.
1 Q: MR. MOSBAUGH HAS TESTIFIED THAT YOU TOLD HIM THAT THE LER 2 REVISION WAS "PUT ON A SHELF" IN THE CORPORATE OFFICE.
3 (ALLEN MOSBAUGH RETYPED PREFILED TESTIMONY AT 38). WAS 4 THERE A DELAY IN THIS LER REVISION'S APPROVAL BY THE i 5 CORPORATE OFFICE?
6 A: Yes. It was unusual for any NRC-related report to go up
, 7 to corporate and not be looked at for several weeks. As 8 part of keeping track of work in progress, I called the 9 corporate office to learn the status of the revision. I 10 was told that the revision had been "put on a shelf" but 11 that it was at that time back in the review process. The 1
12 fifth draft revision, with a cover letter, was sent from j 13 the corporate office to the site for Mr. Bockhold's 14 approval on June lith. Mr. Bockhold approved this l 15 revision with a comment to update the diesel generator l
I 16 start numbers through June lith. This was done, and the 17 red-lined revision was sent back to the corporate office. l 18 Q: HAD THE CORPORATE OFFICE SUGGESTED SUBSTANTIVE REVISIONS
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19 DURING THIS DELAY?
20 A: No. The fifth draft revision was simply put into 21 corporate form and the cover letter developed. I l
22 Q: WHAT DID THE DRAFT COVER LETTER OF JUNE 11, 1990 SAY?
23 A: It simply stated that the revision was necessary to .
24 correct the information related to the number of l
1 successful Diesel Generator starts subsequent to the -!
2 comprehensive test program as discussed in the original I
3 report and Georgia Power's April 9, 1990 letter (ELV-4 01516).
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. t 5 Q: WHAT DID THE DRAFT LER REVISION STATE AFTER UPDATING 6 THROUGH JUNE 11, 1990? ]
7 A: The pertinent language stated:
8 From 3-20-90 to 6-11-90, there were 14 valid tests )
9 of DG1A with no valid failures. During this same I 10 period, there were 11 valid tests of DG1B with one {
11 valid failure, which occurred following j 12 installation of new jacket water temperature 13 switches. A report of this failure will be 14 submitted as Technical Specifications Special 15 Report #1-90-04.
l 16 This was the language approved by Mr. Bockhold on June l 17 11, 1990.
l 18 Q: WHY WAS THERE A CHANGE TO " VALID TESTS" AND " VALID 19 FAILURES" FROM THE ORIGINAL, APRIL 19 LER WHICH DISCUSSED 20 STARTS WITHOUT PROBLEMS OR FAILURES?
21 A: AsIviewedit,thenumberofstartswithouthoblemsor 22 failures as of May 14 or June 11 was meaningless. So the 23 revised draft LER revision of June 11, 1990 adopted our 24 standard practice for reporting diesel generator
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25 failures, which was to count " valid" tests and failures, 26 pursuant to Reg. Guide l.108. (At that time we did not 27 report some problem starts that we now call nonvalid
1 failures.) The June 11 revision (i.e. fifth draft 2 revision) reflected current, updated information although 3 it changed the criteria for counting starts. I thought l 4 this change in criteria was appropriate.
5 Q: WAS A SIXTH DRAFT REVISION PREPARED AND APPROVED?
6 A: Yes. Between June 12th and June 21st a sixth draft 7 revision was prepared and approved by the PRB. This 8 sixth draft contained no " start count" numbers, but 9 incorporated information obtained from Wyle Laboratories, j i
I 10 which had performed testing on the Calcon temperature 11 sensors.
12 Q: WAS THERE A SEVENTH DRAFT REVISION?
l l 13 A: Yes, the corporate office, specifically Harry Majors, l
l 14 sent a seventh draft revision, and a draft cover letter i
15 to the site. The PRB reviewed this draft LER revision 16 and added comments. The " start count" language in this l
17 seventh draft, which had been PRB-approved with comments, l
18 stated:
19 As of 6-7-90, DG1B had received 11 valid tests 20 with one failure, and DG1A had received 16 21 valid tests with no failures.
22 There were a number of cover letter drafts sent to the 23 site from the corporate office on June 28 and June 29, 24 1990. The site does not generally review cover letters, ;
25 which are developed by the corporate office. I provided e
1 these cover letter drafts to Mr. Aufdenkampe.
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2 Q: WHAT WAS YOUR INVOLVEMENT IN REVIEWING THE LER REVISION 3 COVER LETTER, DATED JUNE 29, 1990?
4 A: Based upon my review of a transcript of a conversation 5 recorded by Mr. Mosbaugh, I participated in discussions 6 concerning the cover letter. Mr. Mosbaugh refers to some
. 7 of my participation in his retyped prefiled testimony (at i 8 57). We were using the LER revision as a vehicle to i
9 clarify the April 9 letter as well as to correct the 10 original LER. My understanding was that correcting the 11 original LER was required by NUREG 1022.
} 12 Q: MR. MOSBAUGli MAINTAINS THAT THE LER COVER LETTER WAS 13 WILLFULLY FALSE (ALLEN HOSBAUGH RETYPED PREFILED l 14 TESTIMONY AT 55). DID YOt' THINK THAT THE JUNE 29, 1990 15 LER COVER LETTER CLARIFIES THE INFORMATION RELATING TO i l
- 16 THE NUMBER OF SUCCEGoFUL DIESEL STARTS IN THE APRIL 9 l
- 17 LETTER?
i 18 A: Yes. The April 9th letter is specifically referenced in l 19 the cover letter, and Page 6 of the LER revision, third l I
20 paragraph, updates diesel generator start information to j 21 the current time. Although the April 9th letter did not 22 use Regulatory Guide terminology such as " valid test", it 23 was our practice to report valid failures; we are 24 expected to maintain our surveillance frequency based 1
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- 1. .upon the number of valid tests and number of valid 2 failures. Tests and failures that were not " valid" have 3 no bearing on that surveillance frequency. So, to me, ;
4 the LER revision used defiied phrases from a regulatory l
l 5 compliance perspective, and provided more useful .
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6 information. In addition, the cover letter and the April 7 9th letter begin their " counts" after March'20, 1990. ,
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